<\/td> | Unintended anti-clawback bonus<\/td> | 0<\/td> | 880,000<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n That \u201cbonus\u201d is probably what has prompted the IRS and Treasury to consider an \u201canti-abuse provision,\u201d and probably what such an amendment would curtail. Put another way, it would simply preserve the \u201cclawback,\u201d in effect, that provisions like section 2036 have been designed to achieve since at least the 1930s.<\/p>\n\n\n\n Effective Date of the Anti-Abuse Amendment<\/h3>\n\n\n\nIt is likely that the contemplated amendment of the regulations would apply only prospectively \u2013 that is, after the date it is published as a final regulation. But it should also be noted that it would apply only to the calculation of the estate tax when a provision like section 2036 (including those in chapter 14) applies. It should be expected to first apply to the estate of someone who dies after December 31, 2025 (or 2021), when the \u201csunset\u201d enacted in 2017 occurs, Thus, it would achieve the \u201canti-abuse\u201d outcome described above with respect to gifts made and other lifetime actions taken since 2017 that result in estate includability, whether or not those actions are taken before the regulations are amended.<\/p>\n\n\n\n The pending proposal in the House of Representatives to accelerate the \u201csunset\u201d to January 1, 2022, could mean that, unless the \u201canti-abuse\u201d regulations are issued before the end of 2021 (which is possible but by no means certain), some persons who have made post-2017 gifts with potential for inclusion in the gross estate will die before the regulations are effective. Those persons\u2019 estates might benefit from the anti-clawback bonus. Or the regulations might provide for retroactive application to their estates, which is sometimes done in true \u201cabuse\u201d cases. Planning after December 31, 2017, by persons who die after December 31, 2021, and after the regulations are final would be caught in any event.<\/p>\n\n\n\n ITEM 4: EFFECT OF EVENTS BETWEEN DEATH AND THE ALTERNATE VALUATION DATE<\/h2>\n\n\n\nItem 4 is described as \u201cRegulations under \u00a72032(a) regarding imposition of restrictions on estate assets during the six-month alternate valuation period. Proposed regulations were published on November 18, 2011.\u201d This project first appeared in the 2007-2008 Plan.<\/p>\n\n\n\n The first set of proposed regulations related to this project, Proposed Reg. \u00a720.2032-1(f) (REG-112196-07), was published on April 25, 2008. The preamble appeared to view these regulations as the resolution of \u201ctwo judicial decisions [that] have interpreted the language of section 2032 and its legislative history differently in determining whether post-death events other than market conditions may be taken into account under the alternate valuation method.\u201d<\/p>\n\n\n\n Flanders v. United States<\/h3>\n\n\n\nIn the first of these cases, Flanders v. United States, 347 F. Supp. 95 (N.D. Calif. 1972), after a decedent\u2019s death in 1968, but before the alternate valuation date, the trustee of the decedent\u2019s (formerly) revocable trust, which held a one-half interest in a California ranch, entered into a land conservation agreement pursuant to California law. The conservation agreement reduced the value of the ranch by 88 percent. Since that reduced value was the value of the ranch at the alternate valuation date (which until 1971 was one year after death), the executor elected alternate valuation and reported the ranch at that value.<\/p>\n\n\n\n Citing the Depression-era legislative history to the effect that alternate valuation was intended to protect decedents\u2019 estates against \u201cmany of the hardships which were experienced after 1929 when market values decreased very materially between the period from the date of death and the date of distribution to the beneficiaries,\u201d the court held that \u201cthe value reducing result of the post mortem act of the surviving trustee\u201d may not be considered in applying alternate valuation.<\/p>\n\n\n\n Kohler v. Commissioner<\/h3>\n\n\n\nThe second of these cases was Kohler v. Commissioner, T.C. Memo. 2006-152, nonacq., 2008-9 I.R.B. 481, involving the estate of a shareholder of the well-known family-owned plumbing fixture manufacturer. The executor had received stock in a tax-free corporate reorganization that had been under consideration for about two years before the decedent\u2019s death but was not completed until about two months after the decedent\u2019s death.<\/p>\n\n\n\n The court rejected the IRS\u2019s attempt to base the estate tax on the value of the stock surrendered in the reorganization (which had been subject to fewer restrictions on transferability), on the ground that Reg. \u00a720.2032-1(c)(1) prevents that result by specifically refusing to treat stock surrendered in a tax-free reorganization as \u201cotherwise disposed of\u201d for purposes of section 2032(a)(1).<\/p>\n\n\n\n The court also noted that the exchange of stock must have been for equal value or the reorganization would not have been tax-free as the parties had stipulated (although, ironically, the executor\u2019s own appraiser had determined a value of the pre-reorganization shares of $50.115 million and a value of the post-reorganization shares of $47.010 million \u2013 a difference of about 6.2 percent). The court distinguished Flanders, where the post-death transaction itself reduced the value by 88 percent.<\/p>\n\n\n\n The Tax Court in Kohler viewed the 1935 legislative history relied on in Flanders as irrelevant, because Reg. \u00a720.2032-1(c)(1) (promulgated in 1958) was clear and unambiguous and because \u201cthe legislative history describes the general purpose of the statute, not the specific meaning of \u2018otherwise disposed of\u2019 in the context of tax-free reorganizations.\u201d<\/p>\n\n\n\n The First Proposed Regulations<\/h3>\n\n\n\nThe 2008 proposed regulations would have made no change to Reg. \u00a720.2032-1(c)(1), on which the Kohler court relied. But they invoked \u201cthe general purpose of the statute\u201d that <\/p>\n\n\n\n was articulated in 1935, relied on in Flanders but bypassed in Kohler, to beef up Reg. \u00a720.2032-1(f) and to clarify and emphasize, with both text and examples, that the benefits of alternate valuation are limited to changes in value due to \u201cmarket conditions.\u201d The 2008 proposed regulations would specifically add \u201cpost-death events other than market conditions\u201d to changes in value resulting from the \u201cmere lapse of time,\u201d which are ignored in determining the alternate value under section 2032(a)(3).<\/p>\n\n\n\n The Second Proposed Regulations<\/h3>\n\n\n\nNew proposed regulations (REG-112196-07) were published on November 18, 2011. In language that actually seems to have foreshadowed the public reaction to the section 2704 regulations proposed in 2016, the 2011 preamble stated:<\/p>\n\n\n\n \u201c\u2026 Some commentators expressed concern that the proposed regulations (73 FR 22300) would create administrative problems because an estate would be required to trace property and to obtain appraisals based on hypothetical property.\u2026<\/p>\n\n\n\n \u201cIn view of the comments, the Treasury Department and the IRS are withdrawing the proposed regulations (73 FR 22300) by the publication of these proposed regulations in the Federal Register.\u201d<\/p>\n\n\n\n In contrast to the 2008 approach of ignoring certain intervening events \u2013 and thereby potentially valuing assets six months after death on a hypothetical basis \u2013 the new approach is to expand the description of intervening events that are regarding as dispositions, triggering alternate valuation as of that date. The expanded list, in Proposed Reg. \u00a720.2032-1(c)(1)(i), includes distributions, exchanges (whether taxable or not), and contributions to capital or other changes to the capital structure or ownership of an entity, including \u201cthe dilution of the decedent\u2019s ownership interest in the entity due to the issuance of additional ownership interests in the entity.\u201d Proposed Reg. \u00a720.2032-1(c)(1)(i)(I)(1). But under Proposed Reg. \u00a720.2032-1(c)(1)(ii), an exchange of interests in a corporation, partnership, or other entity is not counted if the fair market values of the interests before and after the exchange differ by no more than 5 percent (which would still subject a 6.2 percent difference as in Kohler to the new rules).<\/p>\n\n\n\n If the interest involved is only a fraction of the decedent\u2019s total interest, an aggregation rule in Proposed Reg. \u00a720.2032-1(c)(1)(iv) values such interests at a pro rata share of the decedent\u2019s total interest. The proposed regulations also include special rules for coordinating with annuities and similar payments (\u00a720.2032-1(c)(1)(iii)(B)) and excepting qualified conservation easements (\u00a720.2032-1(c)(4)), and also many more examples (\u00a720.2032-1(c)(5), (e) Example (2), (f)(2)(B) & (f)(3)).<\/p>\n\n\n\n The 2008 proposed regulations were to be effective April 25, 2008, the date the proposed regulations were published. The 2011 proposed regulations, more traditionally, state that they will be effective when published as final regulations.<\/p>\n\n\n\n Applications<\/h3>\n\n\n\nWhile the 2008 proposed regulations were referred to as the \u201canti-Kohler regulations,\u201d the most significant impact of these proposed regulations may fall on efforts to bootstrap an estate into a valuation discount by distributing or otherwise disposing of a minority or other noncontrolling interest within the six-month period after death (valuing it as a minority interest under section 2032(a)(1)) and leaving another minority or noncontrolling interest to be valued six months after death (also valued as a minority interest under section 2032(a)(2)).<\/p>\n\n\n\n Examples 7 and 8 of Proposed Reg. \u00a720.2032-1(c)(5) specifically address the discount-bootstrap technique \u2013 Example 8 in the context of a limited liability company and Example 7 in the context of real estate \u2013 and leave no doubt that changes in value due to \u201cmarket conditions\u201d do not include the valuation discounts that might appear to be created by partial distributions.<\/p>\n\n\n\n And perhaps most significantly, Example 1 reaches the same result with respect to the post-death formation of a limited partnership.<\/p>\n\n\n\n ITEM 5: EFFECT OF GUARANTEES AND PRESENT VALUE CONCEPTS ON ESTATE TAX DEDUCTIONS<\/h2>\n\n\n\nItem 5 is described as \u201cRegulations under \u00a72053 regarding personal guarantees and the application of present value concepts in determining the deductible amount of expenses and claims against the estate.\u201d<\/p>\n\n\n\n This project first appeared in the 2008-2009 Plan as an outgrowth of the project that led to the final amendments of the section 2053 regulations in October 2009, when Treasury and the IRS, as they were to do two years later regarding the \u201canti-Kohler regulations,\u201d acknowledged public criticism of an element of the proposed regulations. That acknowledgment highlighted the significance of present value concepts, as elaborated in this paragraph in the preamble to the 2009 regulations (T.D. 9468, 74 Fed. Reg. 53652 (Oct. 20, 2009)):<\/p>\n\n\n\n \u201cSome commentators suggested that the disparate treatment afforded noncontingent obligations (deduction for present value of obligations) versus contingent obligations (dollar-for-dollar deduction as paid) is inequitable and produces an inconsistent result without meaningful justification. These commentators requested that the final regulations allow an estate to choose between deducting the present value of a noncontingent recurring payment on the estate tax return, or instead deducting the amounts paid in the same manner as provided for a contingent obligation (after filing an appropriate protective claim for refund). The Treasury Department and the IRS find the arguments against the disparate treatment of noncontingent and contingent obligations to be persuasive. The final regulations eliminate the disparate treatment by removing the present value limitation applicable only to noncontingent recurring payments. The Treasury Department and the IRS believe that the issue of the appropriate use of present value in determining the amount of the deduction allowable under section 2053 merits further consideration. The final regulations reserve \u00a7 20.2053-1(d)(6) to provide future guidance on this issue.\u201d<\/p>\n\n\n\n But it is easy to see how the Treasury Department\u2019s and the IRS\u2019s \u201cfurther consideration\u201d of \u201cthe appropriate use of present value concepts\u201d could turn their focus to the leveraged benefit in general that can be obtained when a claim or expense is paid long after the due date of the estate tax, but the additional estate tax reduction is credited as of, and earns interest from, that due date. Graegin loans (see Estate of Graegin v. Commissioner, T.C. Memo. 1988-477) could be an obvious target of such consideration.<\/p>\n\n\n\n If this project results in a deduction of only the present value of the payment, as of the due date of the tax, and the discount rate used in the calculation of the present value is the same as the rate of interest on the tax refund, and the interest is not subject to income tax (or the discount rate is also reduced by the income tax rate), then the invocation of \u201cpresent value concepts\u201d might make very little difference on paper. But it might require legislation to accomplish all these things. And because claims or expenses are rarely paid exactly on the due date of the tax, the precise application of such principles might be exceedingly complicated.<\/p>\n\n\n\n ITEMS 6 AND 7: ALLOCATION OF GST EXEMPTION<\/h2>\n\n\n\nContext of Item 7 of the Priority Guidance Plan<\/h3>\n\n\n\nItem 7 is described as \u201cFinal regulations under \u00a72642(g) describing the circumstances and procedures under which an extension of time will be granted to allocate GST exemption.\u201d This project first appeared in the 2007-2008 Plan.<\/p>\n\n\n\n The background of this project is section 564(a) of the 2001 Tax Act, which added subsection (g)(1) to section 2642, directing Treasury to publish regulations providing for extensions of time to allocate GST exemption or to elect out of statutory allocations of GST exemption (when those actions are missed on the applicable return or a return is not filed). Before the 2001 Tax Act, similar extensions of time under Reg. \u00a7301.9100-3 (so-called \u201c9100 relief\u201d) were not available, because the deadlines for taking such actions were prescribed by the Code, not by the regulations.<\/p>\n\n\n\n The legislative history of the 2001 Tax Act stated that \u201cno inference is intended with respect to the availability of relief from late elections prior to the effective date of [section 2642(g)(1)],\u201d and section 2642(g)(1)(A) itself directs that the regulations published thereunder \u201cshall include procedures for requesting comparable relief with respect to transfers made before the date of the enactment of [section 2642(g)(1)].\u201d Section 2642(g)(1)(B) adds:<\/p>\n\n\n\n \u201cIn determining whether to grant relief under this paragraph, the Secretary shall take into account all relevant circumstances, including evidence of intent contained in the trust instrument or instrument of transfer and such other factors as the Secretary deems relevant. For purposes of determining whether to grant relief under this paragraph, the time for making the allocation (or election) shall be treated as if not expressly prescribed by statute.\u201d<\/p>\n\n\n\n Shortly after the enactment of the 2001 Tax Act, Notice 2001-50, 2001-2 C.B. 189, acknowledged section 2642(g)(1) and stated that taxpayers may seek extensions of time to take those actions under Reg. \u00a7301.9100-3. The Service has received and granted many requests for such relief over the years since the publication of Notice 2001-50.<\/p>\n\n\n\n In addition, Rev. Proc. 2004-46, 2004-2 C.B. 142, provides a simplified method of dealing with pre-2001 gifts that meet the requirements of the annual gift tax exclusion under section 2503(b) but not the special \u201ctax-vesting\u201d requirements applicable for GST tax purposes to gifts in trust under section 2642(c)(2). Gifts subject to Crummey powers are an example. In such cases, GST exemption may be allocated on a Form 709 labeled \u201cFILED PURSUANT TO REV. PROC. 2004-46,\u201d whether or not a Form 709 had previously been filed for that year. Post-2000 gifts are addressed by the expanded deemed allocation rules of section 2632(c), enacted by the 2001 Tax Act.<\/p>\n\n\n\n Proposed Reg. \u00a726.2642-7 (REG-147775-06) was released on April 16, 2008. When finalized, it will oust Reg. \u00a7301.9100-3 and become the exclusive basis for seeking the extensions of time Congress mandated in section 2642(g)(1) (except that the simplified procedure for dealing with pre-2001 annual exclusion gifts under Rev. Proc. 2004-46 will be retained). The proposed regulations resemble Reg. \u00a7301.9100-3, but with some important differences. Under Proposed Reg. \u00a726.2642-7(d)(1), the general standard is still \u201cthat the transferor or the executor of the transferor\u2019s estate acted reasonably and in good faith, and that the grant of relief will not prejudice the interests of the Government.\u201d<\/p>\n\n\n\n Factors<\/h3>\n\n\n\nProposed Reg. \u00a726.2642-7(d)(2) sets forth a \u201cnonexclusive list of factors\u201d to determine whether the transferor or the executor of the transferor\u2019s estate acted reasonably and in good faith, including (i) the intent of the transferor to make a timely allocation or election, (ii) intervening events beyond the control of the transferor or the executor, (iii) lack of awareness of the need to allocate GST exemption to the transfer, despite the exercise of reasonable diligence, (iv) consistency by the transferor, and (v) reasonable reliance on the advice of a qualified tax professional.<\/p>\n\n\n\n Proposed Reg. \u00a726.2642-7(d)(3) sets forth a \u201cnonexclusive list of factors\u201d to determine whether the interests of the Government are prejudiced, including (i) the extent to which the request for relief is an effort to benefit from hindsight, (ii) the timing of the request for relief, and (iii) any intervening taxable termination or taxable distribution.<\/p>\n\n\n\n Noticeably, the proposed regulations seem to invite more deliberate weighing of all those factors than the identification of one or two dispositive factors as under Reg. \u00a7301.9100-3.<\/p>\n\n\n\n \u201cHindsight,\u201d which could be both a form of bad faith and a way the interests of the Government are prejudiced, seems to be a focus of the proposed regulations. This is probably explained by the obvious distinctive feature of the GST tax \u2013 its effects are felt for generations, in contrast to most \u201c9100 relief\u201d elections that affect only a current year or a few years. There simply is more opportunity for \u201chindsight\u201d over such a long term. Thus, the greater rigor required by the proposed regulations seems to be justified by the nature of the GST tax and consistent with the mandate of section 2642(g)(1)(B) to \u201ctake into account all relevant circumstances.\u201d <\/p>\n\n\n\n Affidavits<\/h3>\n\n\n\nProposed Reg. \u00a726.2642-7(h)(3)(i)(D) requires a request for relief to be accompanied by \u201cdetailed affidavits\u201d from \u201ceach tax professional who advised or was consulted by the transferor or the executor of the transferor\u2019s estate with regard to any aspect of the transfer, the trust, the allocation of GST exemption, and\/or the election under section 2632(b)(3) or (c)(5).\u201d<\/p>\n\n\n\n The references to \u201cany aspect of the transfer\u201d and \u201cthe trust\u201d appear to go beyond the procedural requirement of Reg. \u00a7301.9100-3(e)(3) for \u201cdetailed affidavits from the individuals having knowledge or information about the events that led to the failure to make a valid regulatory election and to the discovery of the failure.\u201d Presumably, a professional who advised only with respect to \u201cthe transfer\u201d or \u201cthe trust\u201d would have nothing relevant to contribute other than a representation that they did not advise the transferor to make the election, a fact that the transferor\u2019s own affidavit could establish.<\/p>\n\n\n\n Status and Predictions<\/h3>\n\n\n\nSection 2642(g)(1) itself, having been enacted by the 2001 Tax Act, was once scheduled to \u201csunset\u201d on January 1, 2011, then on January 1, 2013, and is now permanent. These regulations ought to have been close to completion for a long time.<\/p>\n\n\n\n The current Item 7 last appeared in the 2015-2016 Plan. It was removed in the 2016-2017 Plan. Then it was revived in the 2017-2018 Plan. Like the consistent basis regulations, it appeared under the heading of \u201cBurden Reduction\u201d project. How can this be, when the proposed regulations would generally be more burdensome than Reg. \u00a7301.9100-3, which Notice 2001-50 now allows to be used? <\/p>\n\n\n\n As noted above, the multi-generational context of these issues and the mandate of section 2642(g)(1)(B) to \u201ctake into account all relevant circumstances, including evidence of intent \u2026 in the trust instrument\u201d do seem to justify greater substantive analysis. Indeed, the specific reference to \u201cintent\u201d and \u201cthe trust instrument\u201d could actually make it easier to support a finding that an election was appropriate but was missed, when actual witnesses are not available. But perhaps the extensive experience of the IRS with ruling requests under Notice 2001-50 and Reg. \u00a7301.9100-3 has shown that less onerous procedural requirements may be sufficient, especially with respect to the excessive requirements of affidavits, again when witnesses are not available.<\/p>\n\n\n\n Item 6 of the Priority Guidance Plan<\/h3>\n\n\n\nItem 6 is described as \u201cRegulations under \u00a72632 providing guidance governing the allocation of generation-skipping transfer (GST) exemption in the event the IRS grants relief under \u00a72642(g), as well as addressing the definition of a GST trust under \u00a72632(c), and providing ordering rules when GST exemption is allocated in excess of the transferor\u2019s remaining exemption.\u201d It is the only new item under the heading of \u201cGifts and Estates and Trusts\u201d in the 2021-2022 Plan.<\/p>\n\n\n\n It is evidently related to Item 7 and is intended to address not only the consequences of the relief described in Item 7 but also, as the description says, the definition of a \u201cGST trust\u201d and ordering rules when too much GST exemption is ostensibly allocated.<\/p>\n\n\n\n ITEM 8: TAXATION OF TRANSFERS FROM CERTAIN EXPATRIATES<\/h2>\n\n\n\nIt is hard to remember when we last had a reason to discuss section 2801!<\/p>\n\n\n\n The Heroes Earnings Assistance and Relief Tax Act of 2008 (the \u201cHEART\u201d Act) enacted a new income tax \u201cmark to market\u201d rule (section 877A) when someone expatriates on or after June 17, 2008, and a new succession tax on the receipt of certain gifts or bequests from someone who expatriated on or after June 17, 2008. The new succession tax is provided for in section 2801, comprising all of new chapter 15.<\/p>\n\n\n\n Item 8 of the 2021-2022 Priority Guidance Plan is described as \u201cFinal regulations under \u00a72801 regarding the tax imposed on U.S. citizens and residents who receive gifts or bequests from certain expatriates. Proposed regulations were published on September 10, 2015.\u201d This project first appeared on the 2008-2009 Priority Guidance Plan, but was dropped from the Plans during the Trump Administration.<\/p>\n\n\n\n Now it\u2019s back, but it won\u2019t be easy!<\/p>\n\n\n\n Initial Responses<\/h3>\n\n\n\nReferring to the guidance contemplated by this project, Announcement 2009-57, 2009-29 I.R.B. 158 (released July 16, 2009), helpfully stated:<\/p>\n\n\n\n \u201cThe Internal Revenue Service intends to issue guidance under section 2801, as well as a new Form 708 on which to report the receipt of gifts and bequests subject to section 2801. The due date for reporting, and for paying any tax imposed on, the receipt of such gifts or bequests has not yet been determined. The due date will be contained in the guidance, and the guidance will provide a reasonable period of time between the date of issuance of the guidance and the date prescribed for the filing of the return and the payment of the tax.\u201d<\/p>\n\n\n\n Nevertheless, it seems likely that the longer it takes to finalize these regulations consistently with the June 17, 2008, effective date the harder it is going to be, and that the harder it is the longer it might take. A dilemma that has led some to think that this provision of the HEART Act will never take effect, and that Congress must intervene to provide a more workable approach.<\/p>\n\n\n\n When this project first appeared on the 2008-2009 Plan, Treasury and IRS personnel referred to it as a top priority. Evidently the implementation of what amounts to a succession tax on transferees, not transferors or their estates, is quite complicated and challenging. Perhaps the current interest in broader proposed deemed realization legislation (like that discussed in Capital Letter Number 52<\/a>) has given this project new cause for optimism, or pessimism, as the case may be.<\/p>\n\n\n\nProposed Regulations<\/h3>\n\n\n\nThe regulations proposed in 2015 (\u00a7\u00a728.2801-1 through -7 and related procedural sections, REG-112997-10) are about 18,000 words long and were accompanied by a preamble of about 8,600 words. The preamble included the estimate that there would be 1,000 respondents annually.<\/p>\n\n\n\n Proposed Reg. \u00a728.6011-1(a) provides that \u201ccovered\u201d gifts and bequests must be reported by the recipient on Form 708, \u201cUnited States Return of Tax for Gifts and Bequests from Covered Expatriates.\u201d Under Proposed Reg. \u00a728.6071-1(a)(1), Form 708 is generally due on the 15th day of the 18th month following the close of the calendar year in which the transfer was received. But, fulfilling the promise of Announcement 2009-57, Proposed Reg. \u00a728.6071-1(d) states that no Form 708 will be due before the date specified in the final regulations. Under Proposed Reg. \u00a728.2801-3(c)(1) and (2), if a gift or bequest is reported by the expatriate donor or executor of the expatriate decedent on a Form 709 or 706, and gift or estate tax is paid, it is not a covered gift or bequest and need not be reported on Form 708.<\/p>\n\n\n\n Proposed Reg. \u00a728.2801-3(b) confirms that covered bequests include the receipt of assets the value of which would be included in a U.S. citizen\u2019s gross estate under section 2036, 2037, 2038, 2040, 2042, or 2044.<\/p>\n\n\n\n Some Oddities and Surprises in the Calculation of the Tax<\/h3>\n\n\n\nUnder Proposed Reg. \u00a728.2801-4(b)(2), the sum of both covered gifts and covered bequests is reduced by the annual exclusion amount provided for gift tax purposes under section 2503(b). But only one such reduction is allowed, regardless of the number of donors. In the case of a gift to a spouse who is not a U.S. citizen, that amount is determined under section 2523(i) (see Proposed Reg. \u00a728.2801-3(c)(4) and -3(f), Example 1) and is 10 times the unrounded amount determined under section 2503(b).<\/p>\n\n\n\n Under section 2801(b), the tax is an obligation of the recipient. Nevertheless, under the calculation rules in Proposed Reg. \u00a728.2801-4(b), the gift tax the recipient pays is not deducted from the amount subject to tax, as it would be in the case of a typical \u201cnet gift.\u201d The section 2801 tax, whether on a gift or a bequest, is \u201ctax-inclusive.\u201d<\/p>\n\n\n\n Proposed Reg. \u00a728.2801-4(a)(2)(iii) provides rules for computing the tax in the case of a covered transfer to a charitable remainder trust. The value of the transferred property is allocated between the noncharitable interest and the charitable remainder interest in the usual way and the tax is calculated on the noncharitable portion. Although the payment of the tax by the trust does not reduce the value of the gift for purposes of the calculation of the section 2801 tax, it does reduce the value of the charitable remainder and therefore might actually increase the value of the covered gift.<\/p>\n\n\n\n Under Proposed Reg. \u00a728.2801-6(a), the recipient\u2019s payment of the tax does not increase the basis of the transferred property.<\/p>\n\n\n\n Getting the Necessary Information<\/h3>\n\n\n\nOne of the most vexing issues regarding the section 2801 tax has been figuring out how the recipient will know when a gift or bequest is a \u201ccovered\u201d gift or bequest from a \u201ccovered\u201d expatriate. Gifts and bequests normally have no tax consequences to the recipient. Proposed Reg. \u00a728.2801-7(a) provides this ominous and exasperating, but probably unavoidable, confirmation:<\/p>\n\n\n\n \u201c(a) Responsibility of recipients of gifts and bequests from expatriates. It is the responsibility of the taxpayer (in this case, the U.S. citizen or resident receiving a gift or bequest from an expatriate or a distribution from a foreign trust funded at least in part by an expatriate) to ascertain the taxpayer\u2019s obligations under section 2801, which includes making the determination of whether the transferor is a covered expatriate and whether the transfer is a covered gift or covered bequest.\u201d<\/p>\n\n\n\n Apparently doing the best it can to be helpful, Proposed Reg. \u00a728.2801-7(b) adds:<\/p>\n\n\n\n \u201c(b) Disclosure of return and return information\u2014(1) In general. In certain circumstances, the Internal Revenue Service (IRS) may be permitted, upon request of a U.S. citizen or resident in receipt of a gift or bequest from an expatriate, to disclose to the U.S. citizen or resident return or return information of the donor or decedent expatriate that may assist the U.S. citizen or resident in determining whether the donor or decedent was a covered expatriate and whether the transfer was a covered gift or covered bequest. The U.S. citizen or resident may not rely upon this information, however, if the U.S. citizen or resident knows, or has reason to know, that the information received from the IRS is incorrect. The circumstances under which such information may be disclosed to a U.S. citizen or resident, and the procedures for requesting such information from the IRS, will be as provided by publication in the Internal Revenue Bulletin (see \u00a7601.601(d)(2)(ii)(b)).<\/p>\n\n\n\n \u201c(2) Rebuttable presumption. Unless a living donor expatriate authorizes the disclosure of his or her relevant return or return information to the U.S. citizen or resident receiving the gift, there is a rebuttable presumption that the donor is a covered expatriate and that the gift is a covered gift. A taxpayer who reasonably concludes that a gift or bequest is not subject to section 2801 may file a protective Form 708 in accordance with \u00a728.6011-1(b) to start the period for the assessment of any section 2801 tax.\u201d<\/p>\n\n\n\n The preamble further explains:<\/p>\n\n\n\n \u201cSection 28.2801-7 provides guidance on the responsibility of a U.S. recipient, as defined in \u00a728.2801-2(e), to determine if tax under section 2801 is due. The Treasury Department and the IRS realize that, because the tax imposed by this section is imposed on the U.S. citizen or resident receiving a covered gift or covered bequest, rather than on the donor or decedent covered expatriate making the gift or bequest, U.S. taxpayers may have difficulty determining whether they are liable for any tax under section 2801. Nevertheless, the same standard of due diligence that applies to any other taxpayer to determine whether the taxpayer has a tax liability or a filing requirement also applies to U.S. citizens and residents under this section. Accordingly, it is the responsibility of each U.S. citizen or resident receiving a gift or bequest, whether directly or indirectly, from an expatriate (as defined in section 877A(g)(2)) to determine its tax obligations under section 2801. Thus, the burden is on that U.S. citizen or resident to determine whether the expatriate was a covered expatriate (as defined in section 877A(g)(1)) and, if so, whether the gift or bequest was a covered gift or covered bequest.\u201d<\/p>\n\n\n\n In other words, if a family member expatriates, life will be tougher for other family members (or any objects of the expatriate\u2019s bounty) who do not expatriate.<\/p>\n\n\n\n Proposed Reg. \u00a728.6011-1(b)(i) does provide that a recipient who reasonably concludes that a gift or bequest is not a \u201ccovered\u201d gift or bequest may file a protective Form 708, and that such a filing will start the period for assessment of tax with respect to any transfer reported on that return.<\/p>\n\n\n\n More Math<\/h3>\n\n\n\nSection 2801(e)(1) provides that a \u201ccovered gift or bequest\u201d includes any property acquired \u201cdirectly or indirectly.\u201d Section 2801(e)(4)(A) provides that a covered transfer includes a transfer to a U.S. domestic trust. Section 2801(e)(4)(B)(i) provides that in the case of a covered gift or bequest to a foreign trust, the tax is imposed on distributions from the trust \u201cattributable to such gift or bequest.\u201d<\/p>\n\n\n\n Proposed Reg. \u00a728.2801-5(c)(1)(i) provides that the amount of any distribution attributable to covered gifts and bequests is determined by applying a \u201csection 2801 ratio\u201d to the value of the distribution. Tracing of particular trust assets is not allowed. Under Proposed Reg. \u00a728.2801-5(c)(1)(ii), the \u201csection 2801 ratio,\u201d representing the portion of the trust and of each distribution that is deemed to be attributable to covered transfers, is redetermined after each contribution to the trust in a manner resembling the calculation of the inclusion ratio for GST tax purposes. Proposed Reg. \u00a728.2801-5(c)(3) provides:<\/p>\n\n\n\n \u201cIf the trustee of the foreign trust does not have sufficient books and records to calculate the section 2801 ratio, or if the U.S. recipient is unable to obtain the necessary information with regard to the foreign trust, the U.S. recipient must proceed upon the assumption that the entire distribution for purposes of section 2801 is attributable to a covered gift or covered bequest.\u201d<\/p>\n\n\n\n This encourages the expatriate transferor to cooperate with transferees.<\/p>\n\n\n\n Elections and Appointments<\/h3>\n\n\n\nProposed Reg. \u00a728.2801-5(d) permits a foreign trust to elect to be treated as a U.S. domestic trust. Thereby the section 2801 tax is imposed on the value of the trust multiplied by the section 2801 ratio and on all current and future transfers to the trust from covered expatriates, but not on future distributions from the trust.<\/p>\n\n\n\n The trustee of an electing foreign trust must designate and authorize a U.S. agent solely for purposes of section 2801. Proposed Reg. \u00a728.2801-5(d)(3)(iv) states:<\/p>\n\n\n\n \u201cBy designating a U.S. agent, the trustee of the foreign trust agrees to provide the agent with all information necessary to comply with any information request or summons issued by the Secretary. Such information may include, without limitation, copies of the books and records of the trust, financial statements, and appraisals of trust property. \u2026 Acting as an agent for the trust for purposes of section 2801 includes serving as the electing foreign trust\u2019s agent for purposes of section 7602 (\u2018Examination of books and witnesses\u2019), section 7603 (\u2018Service of summons\u2019), and section 7604 (\u2018Enforcement of summons\u2019) with respect to \u2026 any request by the Secretary to examine records or produce testimony related to the proper identification or treatment of covered gifts or covered bequests contributed to the electing foreign trust and distributions attributable to such contributions; and \u2026 any summons by the Secretary for records or testimony related to the proper identification or treatment of covered gifts or covered bequests contributed to the electing foreign trust and distributions attributable to such contributions.\u201d<\/p>\n\n\n\n Care would be advisable in agreeing to be a U.S. agent.<\/p>\n\n\n\n ITEM 9: ACTUARIAL TABLES<\/h2>\n\n\n\nItem 9 is described as \u201cRegulations under \u00a77520 regarding the use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests.\u201d This item was new in the 2018-2019 Plan.<\/p>\n\n\n\n The current mortality tables, based on 2000 census data, became effective May 1, 2009. Previous mortality tables had taken effect on May 1, 1989, and May 1, 1999. Section 7520(c)(2) mandates revision of the tables at least once every ten years. This project is that routine revision, to reflect 2010 census data and to be effective as of May 1, 2019, even though it was not completed by that date. Now, almost two and a half years late, it must be almost done!<\/p>\n\n\n\n When completed, the tables will reflect longer life expectancies. Thus, for example, for trusts lasting for life, there will be:<\/p>\n\n\n\n \n- lower values in general for remainder interests;<\/li>\n\n\n\n
- larger charitable deductions for charitable lead annuity trusts (CLATs);<\/li>\n\n\n\n
- smaller charitable deductions for charitable remainder annuity trusts (CRATs);<\/li>\n\n\n\n
- more difficulty satisfying the at-least-10-percent-remainder test for CRATs imposed by section 664(d)(1)(D); and<\/li>\n\n\n\n
- more difficulty satisfying the not-more-than-5-percent-possibility-of-exhaustion test for CRATs elaborated and applied in Rev. Rul. 70-452, 1970-2 C.B. 199.<\/li>\n<\/ul>\n\n\n\n
Transitional Relief?<\/h3>\n\n\n\nIt is reasonable to assume that there will be transitional relief for taxpayers who, since May 1, 2019, have relied on the mortality tables that took effect May 1, 2009. Because the mortality tables have not been late before, there is no model for such transitional relief. But even the timely promulgation of the 2009 mortality tables provided two months of relief the preamble described as \u201ccertain transitional rules intended to alleviate any adverse consequences resulting from the proposed regulatory change.\u201d T.D. 9448, 74 Fed. Reg. 21438, 21439 (May 7, 2009). The preamble elaborated:<\/p>\n\n\n\n \u201cFor gift tax purposes, if the date of a transfer is on or after May 1, 2009, but before July 1, 2009, the donor may choose to determine the value of the gift (and\/or any applicable charitable deduction) under tables based on either [the 1990 or 2000 census data]. Similarly, for estate tax purposes, if the decedent dies on or after May 1, 2009, but before July 1, 2009, the value of any interest (and\/or any applicable charitable deduction) may be determined in the discretion of the decedent\u2019s executor under tables based on either [the 1990 or 2000 census data]. However, the section 7520 interest rate to be utilized is the appropriate rate for the month in which the valuation date occurs, subject to the \u2026 special rule [in section 7520(a)] for certain charitable transfers.\u201d<\/p>\n\n\n\n In other words, transitional relief may be provided with respect to the actuarial components of calculations based on mortality (life expectancy) tables, but not with respect to merely financial components such as applicable federal rates and the section 7520 rate, which have been published monthly as usual without interruption. For example, such transitional relief would apply to the calculations since May 1, 2019, of the values of an interest for life, an interest for joint lives, an interest for life or a term whichever is shorter or longer, or a remainder following such an interest. But no transitional relief would be necessary for calculations related to promissory notes or GRATs, for example, that involve only fixed terms without mortality components, which the new mortality tables would not affect.<\/p>\n\n\n\n OMISSIONS FROM THE PRIORITY GUIDANCE PLAN<\/h2>\n\n\n\nThe following topics have been in Priority Guidance Plans in the past but do not appear in the current Plan:<\/p>\n\n\n\n \n- The basis of grantor trust assets under section 1014 (deleted from the 2021-2022 Plan)<\/li>\n\n\n\n
- The valuation of promissory notes (deleted in the Trump Administration)<\/li>\n\n\n\n
- The gift tax effect of defined value clauses (deleted in the Trump Administration)<\/li>\n\n\n\n
- \u201cMaterial participation\u201d by trusts and estates for purposes of the 3.8 percent tax on net investment income under section 1411 (deleted in the Trump Administration)<\/li>\n\n\n\n
- Family-owned trust companies as fiduciaries (deleted in the Obama Administration)<\/li>\n\n\n\n
- Trust decanting (deleted in the Obama Administration)<\/li>\n<\/ul>\n\n\n\n
For detailed discussion of these topics, see Part 4.i of Washington Update<\/a>, available at http:\/\/www.bessemertrust.com\/for-professional-partners\/advisor-insights<\/a>.<\/p>\n\n\n\nRonald D. Aucutt<\/p>\n\n\n\n \u00a9 Copyright 2021 by Bessemer Trust Company, N.A. All rights reserved.<\/p>\n","protected":false},"excerpt":{"rendered":" Amidst the current whirlwind of uncertainty about pending legislation, let\u2019s pause to be reminded of the projects in the somewhat more predictable Treasury – IRS Priority Guidance Plan.<\/p>\n","protected":false},"featured_media":0,"template":"","meta":{"_acf_changed":false,"_tec_requires_first_save":true,"_EventAllDay":false,"_EventTimezone":"","_EventStartDate":"","_EventEndDate":"","_EventStartDateUTC":"","_EventEndDateUTC":"","_EventShowMap":false,"_EventShowMapLink":false,"_EventURL":"","_EventCost":"","_EventCostDescription":"","_EventCurrencySymbol":"","_EventCurrencyCode":"","_EventCurrencyPosition":"","_EventDateTimeSeparator":"","_EventTimeRangeSeparator":"","_EventOrganizerID":[],"_EventVenueID":[],"_OrganizerEmail":"","_OrganizerPhone":"","_OrganizerWebsite":"","_VenueAddress":"","_VenueCity":"","_VenueCountry":"","_VenueProvince":"","_VenueState":"","_VenueZip":"","_VenuePhone":"","_VenueURL":"","_VenueStateProvince":"","_VenueLat":"","_VenueLng":"","_VenueShowMap":false,"_VenueShowMapLink":false,"_tribe_blocks_recurrence_rules":"","_tribe_blocks_recurrence_description":"","_tribe_blocks_recurrence_exclusions":"","footnotes":""},"categories":[1],"class_list":["post-1619","capital-letter","type-capital-letter","status-publish","hentry","category-uncategorized"],"acf":[],"yoast_head":"\n 2021-2022 Treasury - IRS Priority Guidance Plan<\/title>\n\n\n\n\n\n\n\n\n\n\n\n\t\n |